Background - Practices (Details)
Tax
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Representative Engagements

  • Represented client in a trial before the U.S. Court of Federal Claims arising out of tax issues associated with the client's participation in an international partnership. Decision in favor of client.
  • Represent clients before the U.S. District Court and the U.S. Tax Court in connection with issues relating to research and experimental deductions and credits.
  • Represented a client in a proceeding before the U.S. District Court in an administrative summons enforcement action. Decision in favor of client.
  • Represented client in a proceeding before the U.S. District Court to quash a formal document request (under section 982) relating to the admissibility of documents maintained in foreign countries. Favorable settlement negotiated with the IRS.
  • Represented client before the U.S. Tax Court in connection with deduction for expenses to resist hostile takeover attempt. Action settled favorably for client.
  • Represented client before the U.S. Tax Court in connection with section 382 and separate return limitation year issues. The government conceded the case before trial.
  • Represented client before the U.S. Court of Federal Claims in connection with the constitutionality of the harbor maintenance tax. The Supreme Court resolved the issue in favor of the company in a related case.
  • Represented large estate in connection with substantial estate, gift and generation-skipping tax deficiencies. Favorable settlement negotiated with the IRS.
  • Represented client in connection with substantial asserted excise tax deficiencies and related penalties. Favorable settlement negotiated with the IRS.
  • Represent large corporate client in connection with valuation of real estate and other assets donated to a state agency. Case ongoing.
  • Represent client in U.S. Court of Federal Claims in connection with valuation of materials supply contract. Case ongoing.
  • Represented clients in connection with section 6112 summons proceedings relating to potentially abusive tax shelter transactions.
  • Represent client in the U.S. Court of Federal Claims and the Federal Circuit Court of Appeals on propriety of IRS's assertion of executive privilege to withhold discovery. Case ongoing.